Greater Cambridge Local Plan: Proposed Submission

As set out within draft Policy S/JH, the emerging Local Plan seeks to deliver at least 48,069 new homes within the Plan Period (2024-2045). In accordance with paragraph 62 of the National Planning Policy Framework (NPPF), this has been derived through the use of a standard method, which sets an annual requirement of 2,289 dwellings.

Whilst Policy S/JH seeks to meet its Local Housing Need (LHN), it is noted in paragraph 5, that the delivery is made up through the delivery of Neighbourhood Plans. Appendix C sets out that that the Local Plan is requiring 27 Neighbourhood areas to deliver 1,543 homes through Neighbourhood Plans.

Whilst Thakeham supports Neighbourhood Plans being used to deliver benefits to the local community, it does not support the Council’s intention for Neighbourhood Plans to
be relied upon to deliver rural growth. Instead, the Council must plan positively and ensure that the emerging Local Plan allocates sufficient sites to meet its housing need in full and ensure the vitality of rural settlements which the current emerging Local Plan does not seek to do.

The draft policy does not ensure the Local Plan is positively prepared as required under paragraph 36 of the 2024 NPPF, and also fails to recognise that some Neighbourhood Plans which have housing requirements within the draft Local Plan, have recently been ‘made’ and therefore are unlikely to be renewed in the short to medium term. An example of this would be the Fulbourn Neighbourhood Plan which was ‘made’ in March 2023.
Appendix C identifies that the Neighbourhood Plan should allocate a minimum of 101 dwellings; however, the ‘made’ Neighbourhood Plan does not allocate a single allocation,
therefore significantly short of the housing requirement set out within Appendix C. Despite the Neighbourhood Plan being three years old, Appendix C is suggesting that the Parish Council will need to go through the Neighbourhood Plan process again to allocate this requirement.

It should also be noted that following the Ministry for Housing, Communities and Local Government’s (MHCLG) announcement in June 2025, MHCLG has withdrawn
Neighbourhood Plan funding and planning support services from 2025 onwards. This announcement means that Neighbourhood Plans are now less likely to come forward, bringing doubt on the delivery of homes through Neighbourhood Plans. Furthermore, Neighbourhood Plans are slow to produce and will therefore not facilitate and enable the delivery of housing in the initial years of the plan. If the Council continues with its current approach, it is difficult to see how it will have five-year housing land supply at the point of adoption, leading to an immediate review and speculative planning applications, which
undermines the purpose of the plan-led system.

Considering the above, the current reliance on 1,543 being delivered through Neighbourhood Plans is an unsuitable method of ensuring housing delivery and results in the draft Local Plan not being prepared positively in accordance with paragraph 15 of the NPPF.

To ensure the prosperity of rural areas and ensure that key community facilities are delivered, the emerging Local Plan should seek to allocate additional sites within the rural area.

The proposed development strategy outlined within Policy S/DS seeks to rely on existing allocations and permissions to deliver 38,378 homes, with an additional 13,654 dwellings identified through brownfield redevelopment, new towns and large-scale strategic allocations. Whilst Thakeham acknowledges and supports that the Council has sought to meet its Local Housing Need (LHN) in full and provide an 8.2% buffer, the spatial strategy
is heavily reliant on the delivery of new settlements and large-scale development on the edge of Cambridge. As outlined in figure 9, previous growth has looked to be fairly evenly split across the different growth distributions. However, the proposed distribution in the emerging Local Plan seeks to deliver nearly half of its growth through ‘new settlements’ with only 15% delivered within the rural area. The underutilisation of the rural area leaves rural settlements vulnerable to seeing community facilities become unviable and therefore close down. By not supporting growth in rural areas, the Local Plan could see rural settlements become less sustainable and more reliant on travel to access key facilities.

As well as the underutilisation of rural growth, the emerging Local Plan seeks to deliver 81% of the homes on sites of 1,000 or more homes. The heavy weighting on largescale strategic sites does not support small and medium sized house builders, and also could impact the ability for sites to come forward in a timely manner to enable a rolling five-year housing land supply.

Appendix D of the Local Plan states that upon adoption (2028), Greater Cambridge will be able to demonstrate a 5.47-year housing land supply. However, this based on the
Liverpool method to assessing housing land supply which is not the method preferred by Government. Paragraph 68-031 of the Planning Practice Guidance (PPG) states that “the level of deficit or shortfall will need to be calculated from the base date of the adopted plan
and should be added to the plan requirements for the next 5 year period (the Sedgefield approach), then the appropriate buffer should be applied”.

With the emerging Local Plan using the Liverpool method, the approach taken is not consistent with the PPG.
If the Local Plan were to use the Sedgefield approach, Greater Cambridge would only be able to demonstrate a 5.03 year supply, which does not provide a suitable buffer. The use of this Method therefore further highlights the issue of the development strategy by using larger strategic sites which would not be delivered until later in the Plan Period. With the approach not being sound or consistent with national policy, the Local Plan should use
the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.

Thakeham advises that the policy should be amended to remove reference of applicants undertaking need assessments, with the policy ensuring all new development includes or contributes to the delivery of the services and facilities necessary to meet the needs of the development and mitigate the impact of development on existing local facilities.

As set out within draft Policy S/JH, the emerging Local Plan seeks to deliver at least 48,069 new homes within the Plan Period (2024-2045). In accordance with paragraph 62 of the National Planning Policy Framework (NPPF), this has been derived through the use of a standard method, which sets an annual requirement of 2,289 dwellings.

Whilst Policy S/JH seeks to meet its Local Housing Need (LHN), it is noted in paragraph 5, that the delivery is made up through the delivery of Neighbourhood Plans. Appendix C sets out that that the Local Plan is requiring 27 Neighbourhood areas to deliver 1,543 homes through Neighbourhood Plans.

Whilst Thakeham supports Neighbourhood Plans being used to deliver benefits to the local community, it does not support the Council’s intention for Neighbourhood Plans to
be relied upon to deliver rural growth. Instead, the Council must plan positively and ensure that the emerging Local Plan allocates sufficient sites to meet its housing need in full and ensure the vitality of rural settlements which the current emerging Local Plan does not seek to do.

The draft policy does not ensure the Local Plan is positively prepared as required under paragraph 36 of the 2024 NPPF, and also fails to recognise that some Neighbourhood Plans which have housing requirements within the draft Local Plan, have recently been ‘made’ and therefore are unlikely to be renewed in the short to medium term. An example of this would be the Fulbourn Neighbourhood Plan which was ‘made’ in March 2023.
Appendix C identifies that the Neighbourhood Plan should allocate a minimum of 101 dwellings; however, the ‘made’ Neighbourhood Plan does not allocate a single allocation,
therefore significantly short of the housing requirement set out within Appendix C. Despite the Neighbourhood Plan being three years old, Appendix C is suggesting that the Parish Council will need to go through the Neighbourhood Plan process again to allocate this requirement.

It should also be noted that following the Ministry for Housing, Communities and Local Government’s (MHCLG) announcement in June 2025, MHCLG has withdrawn
Neighbourhood Plan funding and planning support services from 2025 onwards. This announcement means that Neighbourhood Plans are now less likely to come forward, bringing doubt on the delivery of homes through Neighbourhood Plans. Furthermore, Neighbourhood Plans are slow to produce and will therefore not facilitate and enable the delivery of housing in the initial years of the plan. If the Council continues with its current approach, it is difficult to see how it will have five-year housing land supply at the point of adoption, leading to an immediate review and speculative planning applications, which
undermines the purpose of the plan-led system.

Considering the above, the current reliance on 1,543 being delivered through Neighbourhood Plans is an unsuitable method of ensuring housing delivery and results in the draft Local Plan not being prepared positively in accordance with paragraph 15 of the NPPF.

To ensure the prosperity of rural areas and ensure that key community facilities are delivered, the emerging Local Plan should seek to allocate additional sites within the rural area.

The proposed development strategy outlined within Policy S/DS seeks to rely on existing allocations and permissions to deliver 38,378 homes, with an additional 13,654 dwellings identified through brownfield redevelopment, new towns and large-scale strategic allocations. Whilst Thakeham acknowledges and supports that the Council has sought to meet its Local Housing Need (LHN) in full and provide an 8.2% buffer, the spatial strategy
is heavily reliant on the delivery of new settlements and large-scale development on the edge of Cambridge. As outlined in figure 9, previous growth has looked to be fairly evenly split across the different growth distributions. However, the proposed distribution in the emerging Local Plan seeks to deliver nearly half of its growth through ‘new settlements’ with only 15% delivered within the rural area. The underutilisation of the rural area leaves rural settlements vulnerable to seeing community facilities become unviable and therefore close down. By not supporting growth in rural areas, the Local Plan could see rural settlements become less sustainable and more reliant on travel to access key facilities.

As well as the underutilisation of rural growth, the emerging Local Plan seeks to deliver 81% of the homes on sites of 1,000 or more homes. The heavy weighting on largescale strategic sites does not support small and medium sized house builders, and also could impact the ability for sites to come forward in a timely manner to enable a rolling five-year housing land supply.

Appendix D of the Local Plan states that upon adoption (2028), Greater Cambridge will be able to demonstrate a 5.47-year housing land supply. However, this based on the
Liverpool method to assessing housing land supply which is not the method preferred by Government. Paragraph 68-031 of the Planning Practice Guidance (PPG) states that “the level of deficit or shortfall will need to be calculated from the base date of the adopted plan
and should be added to the plan requirements for the next 5 year period (the Sedgefield approach), then the appropriate buffer should be applied”.

With the emerging Local Plan using the Liverpool method, the approach taken is not consistent with the PPG.
If the Local Plan were to use the Sedgefield approach, Greater Cambridge would only be able to demonstrate a 5.03 year supply, which does not provide a suitable buffer. The use of this Method therefore further highlights the issue of the development strategy by using larger strategic sites which would not be delivered until later in the Plan Period. With the approach not being sound or consistent with national policy, the Local Plan should use
the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.

As set out within draft Policy S/JH, the emerging Local Plan seeks to deliver at least 48,069 new homes within the Plan Period (2024-2045). In accordance with paragraph 62 of the National Planning Policy Framework (NPPF), this has been derived through the use of a standard method, which sets an annual requirement of 2,289 dwellings.

Whilst Policy S/JH seeks to meet its Local Housing Need (LHN), it is noted in paragraph 5, that the delivery is made up through the delivery of Neighbourhood Plans. Appendix C sets out that that the Local Plan is requiring 27 Neighbourhood areas to deliver 1,543 homes through Neighbourhood Plans.

Whilst Thakeham supports Neighbourhood Plans being used to deliver benefits to the local community, it does not support the Council’s intention for Neighbourhood Plans to
be relied upon to deliver rural growth. Instead, the Council must plan positively and ensure that the emerging Local Plan allocates sufficient sites to meet its housing need in full and ensure the vitality of rural settlements which the current emerging Local Plan does not seek to do.

The draft policy does not ensure the Local Plan is positively prepared as required under paragraph 36 of the 2024 NPPF, and also fails to recognise that some Neighbourhood Plans which have housing requirements within the draft Local Plan, have recently been ‘made’ and therefore are unlikely to be renewed in the short to medium term. An example of this would be the Fulbourn Neighbourhood Plan which was ‘made’ in March 2023.
Appendix C identifies that the Neighbourhood Plan should allocate a minimum of 101 dwellings; however, the ‘made’ Neighbourhood Plan does not allocate a single allocation,
therefore significantly short of the housing requirement set out within Appendix C. Despite the Neighbourhood Plan being three years old, Appendix C is suggesting that the Parish Council will need to go through the Neighbourhood Plan process again to allocate this requirement.

It should also be noted that following the Ministry for Housing, Communities and Local Government’s (MHCLG) announcement in June 2025, MHCLG has withdrawn
Neighbourhood Plan funding and planning support services from 2025 onwards. This announcement means that Neighbourhood Plans are now less likely to come forward, bringing doubt on the delivery of homes through Neighbourhood Plans. Furthermore, Neighbourhood Plans are slow to produce and will therefore not facilitate and enable the delivery of housing in the initial years of the plan. If the Council continues with its current approach, it is difficult to see how it will have five-year housing land supply at the point of adoption, leading to an immediate review and speculative planning applications, which
undermines the purpose of the plan-led system.

Considering the above, the current reliance on 1,543 being delivered through Neighbourhood Plans is an unsuitable method of ensuring housing delivery and results in the draft Local Plan not being prepared positively in accordance with paragraph 15 of the NPPF.

To ensure the prosperity of rural areas and ensure that key community facilities are delivered, the emerging Local Plan should seek to allocate additional sites within the rural area.

The proposed development strategy outlined within Policy S/DS seeks to rely on existing allocations and permissions to deliver 38,378 homes, with an additional 13,654 dwellings identified through brownfield redevelopment, new towns and large-scale strategic allocations. Whilst Thakeham acknowledges and supports that the Council has sought to meet its Local Housing Need (LHN) in full and provide an 8.2% buffer, the spatial strategy
is heavily reliant on the delivery of new settlements and large-scale development on the edge of Cambridge. As outlined in figure 9, previous growth has looked to be fairly evenly split across the different growth distributions. However, the proposed distribution in the emerging Local Plan seeks to deliver nearly half of its growth through ‘new settlements’ with only 15% delivered within the rural area. The underutilisation of the rural area leaves rural settlements vulnerable to seeing community facilities become unviable and therefore close down. By not supporting growth in rural areas, the Local Plan could see rural settlements become less sustainable and more reliant on travel to access key facilities.

As well as the underutilisation of rural growth, the emerging Local Plan seeks to deliver 81% of the homes on sites of 1,000 or more homes. The heavy weighting on largescale strategic sites does not support small and medium sized house builders, and also could impact the ability for sites to come forward in a timely manner to enable a rolling five-year housing land supply.

Appendix D of the Local Plan states that upon adoption (2028), Greater Cambridge will be able to demonstrate a 5.47-year housing land supply. However, this based on the
Liverpool method to assessing housing land supply which is not the method preferred by Government. Paragraph 68-031 of the Planning Practice Guidance (PPG) states that “the level of deficit or shortfall will need to be calculated from the base date of the adopted plan
and should be added to the plan requirements for the next 5 year period (the Sedgefield approach), then the appropriate buffer should be applied”.

With the emerging Local Plan using the Liverpool method, the approach taken is not consistent with the PPG.
If the Local Plan were to use the Sedgefield approach, Greater Cambridge would only be able to demonstrate a 5.03 year supply, which does not provide a suitable buffer. The use of this Method therefore further highlights the issue of the development strategy by using larger strategic sites which would not be delivered until later in the Plan Period. With the approach not being sound or consistent with national policy, the Local Plan should use
the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.

As set out within draft Policy S/JH, the emerging Local Plan seeks to deliver at least 48,069 new homes within the Plan Period (2024-2045). In accordance with paragraph 62 of the National Planning Policy Framework (NPPF), this has been derived through the use of a standard method, which sets an annual requirement of 2,289 dwellings.

Whilst Policy S/JH seeks to meet its Local Housing Need (LHN), it is noted in paragraph 5, that the delivery is made up through the delivery of Neighbourhood Plans. Appendix C sets out that that the Local Plan is requiring 27 Neighbourhood areas to deliver 1,543 homes through Neighbourhood Plans.

Whilst Thakeham supports Neighbourhood Plans being used to deliver benefits to the local community, it does not support the Council’s intention for Neighbourhood Plans to
be relied upon to deliver rural growth. Instead, the Council must plan positively and ensure that the emerging Local Plan allocates sufficient sites to meet its housing need in full and ensure the vitality of rural settlements which the current emerging Local Plan does not seek to do.

The draft policy does not ensure the Local Plan is positively prepared as required under paragraph 36 of the 2024 NPPF, and also fails to recognise that some Neighbourhood Plans which have housing requirements within the draft Local Plan, have recently been ‘made’ and therefore are unlikely to be renewed in the short to medium term. An example of this would be the Fulbourn Neighbourhood Plan which was ‘made’ in March 2023.
Appendix C identifies that the Neighbourhood Plan should allocate a minimum of 101 dwellings; however, the ‘made’ Neighbourhood Plan does not allocate a single allocation,
therefore significantly short of the housing requirement set out within Appendix C. Despite the Neighbourhood Plan being three years old, Appendix C is suggesting that the Parish Council will need to go through the Neighbourhood Plan process again to allocate this requirement.

It should also be noted that following the Ministry for Housing, Communities and Local Government’s (MHCLG) announcement in June 2025, MHCLG has withdrawn
Neighbourhood Plan funding and planning support services from 2025 onwards. This announcement means that Neighbourhood Plans are now less likely to come forward, bringing doubt on the delivery of homes through Neighbourhood Plans. Furthermore, Neighbourhood Plans are slow to produce and will therefore not facilitate and enable the delivery of housing in the initial years of the plan. If the Council continues with its current approach, it is difficult to see how it will have five-year housing land supply at the point of adoption, leading to an immediate review and speculative planning applications, which
undermines the purpose of the plan-led system.

Considering the above, the current reliance on 1,543 being delivered through Neighbourhood Plans is an unsuitable method of ensuring housing delivery and results in the draft Local Plan not being prepared positively in accordance with paragraph 15 of the NPPF.

To ensure the prosperity of rural areas and ensure that key community facilities are delivered, the emerging Local Plan should seek to allocate additional sites within the rural area.

The proposed development strategy outlined within Policy S/DS seeks to rely on existing allocations and permissions to deliver 38,378 homes, with an additional 13,654 dwellings identified through brownfield redevelopment, new towns and large-scale strategic allocations. Whilst Thakeham acknowledges and supports that the Council has sought to meet its Local Housing Need (LHN) in full and provide an 8.2% buffer, the spatial strategy
is heavily reliant on the delivery of new settlements and large-scale development on the edge of Cambridge. As outlined in figure 9, previous growth has looked to be fairly evenly split across the different growth distributions. However, the proposed distribution in the emerging Local Plan seeks to deliver nearly half of its growth through ‘new settlements’ with only 15% delivered within the rural area. The underutilisation of the rural area leaves rural settlements vulnerable to seeing community facilities become unviable and therefore close down. By not supporting growth in rural areas, the Local Plan could see rural settlements become less sustainable and more reliant on travel to access key facilities.

As well as the underutilisation of rural growth, the emerging Local Plan seeks to deliver 81% of the homes on sites of 1,000 or more homes. The heavy weighting on largescale strategic sites does not support small and medium sized house builders, and also could impact the ability for sites to come forward in a timely manner to enable a rolling five-year housing land supply.

Appendix D of the Local Plan states that upon adoption (2028), Greater Cambridge will be able to demonstrate a 5.47-year housing land supply. However, this based on the
Liverpool method to assessing housing land supply which is not the method preferred by Government. Paragraph 68-031 of the Planning Practice Guidance (PPG) states that “the level of deficit or shortfall will need to be calculated from the base date of the adopted plan
and should be added to the plan requirements for the next 5 year period (the Sedgefield approach), then the appropriate buffer should be applied”.

With the emerging Local Plan using the Liverpool method, the approach taken is not consistent with the PPG.
If the Local Plan were to use the Sedgefield approach, Greater Cambridge would only be able to demonstrate a 5.03 year supply, which does not provide a suitable buffer. The use of this Method therefore further highlights the issue of the development strategy by using larger strategic sites which would not be delivered until later in the Plan Period. With the approach not being sound or consistent with national policy, the Local Plan should use
the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.

As set out within draft Policy S/JH, the emerging Local Plan seeks to deliver at least 48,069 new homes within the Plan Period (2024-2045). In accordance with paragraph 62 of the National Planning Policy Framework (NPPF), this has been derived through the use of a standard method, which sets an annual requirement of 2,289 dwellings.

Whilst Policy S/JH seeks to meet its Local Housing Need (LHN), it is noted in paragraph 5, that the delivery is made up through the delivery of Neighbourhood Plans. Appendix C sets out that that the Local Plan is requiring 27 Neighbourhood areas to deliver 1,543 homes through Neighbourhood Plans.

Whilst Thakeham supports Neighbourhood Plans being used to deliver benefits to the local community, it does not support the Council’s intention for Neighbourhood Plans to
be relied upon to deliver rural growth. Instead, the Council must plan positively and ensure that the emerging Local Plan allocates sufficient sites to meet its housing need in full and ensure the vitality of rural settlements which the current emerging Local Plan does not seek to do.

The draft policy does not ensure the Local Plan is positively prepared as required under paragraph 36 of the 2024 NPPF, and also fails to recognise that some Neighbourhood Plans which have housing requirements within the draft Local Plan, have recently been ‘made’ and therefore are unlikely to be renewed in the short to medium term. An example of this would be the Fulbourn Neighbourhood Plan which was ‘made’ in March 2023.
Appendix C identifies that the Neighbourhood Plan should allocate a minimum of 101 dwellings; however, the ‘made’ Neighbourhood Plan does not allocate a single allocation,
therefore significantly short of the housing requirement set out within Appendix C. Despite the Neighbourhood Plan being three years old, Appendix C is suggesting that the Parish Council will need to go through the Neighbourhood Plan process again to allocate this requirement.

It should also be noted that following the Ministry for Housing, Communities and Local Government’s (MHCLG) announcement in June 2025, MHCLG has withdrawn
Neighbourhood Plan funding and planning support services from 2025 onwards. This announcement means that Neighbourhood Plans are now less likely to come forward, bringing doubt on the delivery of homes through Neighbourhood Plans. Furthermore, Neighbourhood Plans are slow to produce and will therefore not facilitate and enable the delivery of housing in the initial years of the plan. If the Council continues with its current approach, it is difficult to see how it will have five-year housing land supply at the point of adoption, leading to an immediate review and speculative planning applications, which
undermines the purpose of the plan-led system.

Considering the above, the current reliance on 1,543 being delivered through Neighbourhood Plans is an unsuitable method of ensuring housing delivery and results in the draft Local Plan not being prepared positively in accordance with paragraph 15 of the NPPF.

To ensure the prosperity of rural areas and ensure that key community facilities are delivered, the emerging Local Plan should seek to allocate additional sites within the rural area.

The proposed development strategy outlined within Policy S/DS seeks to rely on existing allocations and permissions to deliver 38,378 homes, with an additional 13,654 dwellings identified through brownfield redevelopment, new towns and large-scale strategic allocations. Whilst Thakeham acknowledges and supports that the Council has sought to meet its Local Housing Need (LHN) in full and provide an 8.2% buffer, the spatial strategy
is heavily reliant on the delivery of new settlements and large-scale development on the edge of Cambridge. As outlined in figure 9, previous growth has looked to be fairly evenly split across the different growth distributions. However, the proposed distribution in the emerging Local Plan seeks to deliver nearly half of its growth through ‘new settlements’ with only 15% delivered within the rural area. The underutilisation of the rural area leaves rural settlements vulnerable to seeing community facilities become unviable and therefore close down. By not supporting growth in rural areas, the Local Plan could see rural settlements become less sustainable and more reliant on travel to access key facilities.

As well as the underutilisation of rural growth, the emerging Local Plan seeks to deliver 81% of the homes on sites of 1,000 or more homes. The heavy weighting on largescale strategic sites does not support small and medium sized house builders, and also could impact the ability for sites to come forward in a timely manner to enable a rolling five-year housing land supply.

Appendix D of the Local Plan states that upon adoption (2028), Greater Cambridge will be able to demonstrate a 5.47-year housing land supply. However, this based on the
Liverpool method to assessing housing land supply which is not the method preferred by Government. Paragraph 68-031 of the Planning Practice Guidance (PPG) states that “the level of deficit or shortfall will need to be calculated from the base date of the adopted plan
and should be added to the plan requirements for the next 5 year period (the Sedgefield approach), then the appropriate buffer should be applied”.

With the emerging Local Plan using the Liverpool method, the approach taken is not consistent with the PPG.
If the Local Plan were to use the Sedgefield approach, Greater Cambridge would only be able to demonstrate a 5.03 year supply, which does not provide a suitable buffer. The use of this Method therefore further highlights the issue of the development strategy by using larger strategic sites which would not be delivered until later in the Plan Period. With the approach not being sound or consistent with national policy, the Local Plan should use
the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.

As set out within draft Policy S/JH, the emerging Local Plan seeks to deliver at least 48,069 new homes within the Plan Period (2024-2045). In accordance with paragraph 62 of the National Planning Policy Framework (NPPF), this has been derived through the use of a standard method, which sets an annual requirement of 2,289 dwellings.

Whilst Policy S/JH seeks to meet its Local Housing Need (LHN), it is noted in paragraph 5, that the delivery is made up through the delivery of Neighbourhood Plans. Appendix C sets out that that the Local Plan is requiring 27 Neighbourhood areas to deliver 1,543 homes through Neighbourhood Plans.

Whilst Thakeham supports Neighbourhood Plans being used to deliver benefits to the local community, it does not support the Council’s intention for Neighbourhood Plans to
be relied upon to deliver rural growth. Instead, the Council must plan positively and ensure that the emerging Local Plan allocates sufficient sites to meet its housing need in full and ensure the vitality of rural settlements which the current emerging Local Plan does not seek to do.

The draft policy does not ensure the Local Plan is positively prepared as required under paragraph 36 of the 2024 NPPF, and also fails to recognise that some Neighbourhood Plans which have housing requirements within the draft Local Plan, have recently been ‘made’ and therefore are unlikely to be renewed in the short to medium term. An example of this would be the Fulbourn Neighbourhood Plan which was ‘made’ in March 2023.
Appendix C identifies that the Neighbourhood Plan should allocate a minimum of 101 dwellings; however, the ‘made’ Neighbourhood Plan does not allocate a single allocation,
therefore significantly short of the housing requirement set out within Appendix C. Despite the Neighbourhood Plan being three years old, Appendix C is suggesting that the Parish Council will need to go through the Neighbourhood Plan process again to allocate this requirement.

It should also be noted that following the Ministry for Housing, Communities and Local Government’s (MHCLG) announcement in June 2025, MHCLG has withdrawn
Neighbourhood Plan funding and planning support services from 2025 onwards. This announcement means that Neighbourhood Plans are now less likely to come forward, bringing doubt on the delivery of homes through Neighbourhood Plans. Furthermore, Neighbourhood Plans are slow to produce and will therefore not facilitate and enable the delivery of housing in the initial years of the plan. If the Council continues with its current approach, it is difficult to see how it will have five-year housing land supply at the point of adoption, leading to an immediate review and speculative planning applications, which
undermines the purpose of the plan-led system.

Considering the above, the current reliance on 1,543 being delivered through Neighbourhood Plans is an unsuitable method of ensuring housing delivery and results in the draft Local Plan not being prepared positively in accordance with paragraph 15 of the NPPF.

To ensure the prosperity of rural areas and ensure that key community facilities are delivered, the emerging Local Plan should seek to allocate additional sites within the rural area.

The proposed development strategy outlined within Policy S/DS seeks to rely on existing allocations and permissions to deliver 38,378 homes, with an additional 13,654 dwellings identified through brownfield redevelopment, new towns and large-scale strategic allocations. Whilst Thakeham acknowledges and supports that the Council has sought to meet its Local Housing Need (LHN) in full and provide an 8.2% buffer, the spatial strategy
is heavily reliant on the delivery of new settlements and large-scale development on the edge of Cambridge. As outlined in figure 9, previous growth has looked to be fairly evenly split across the different growth distributions. However, the proposed distribution in the emerging Local Plan seeks to deliver nearly half of its growth through ‘new settlements’ with only 15% delivered within the rural area. The underutilisation of the rural area leaves rural settlements vulnerable to seeing community facilities become unviable and therefore close down. By not supporting growth in rural areas, the Local Plan could see rural settlements become less sustainable and more reliant on travel to access key facilities.

As well as the underutilisation of rural growth, the emerging Local Plan seeks to deliver 81% of the homes on sites of 1,000 or more homes. The heavy weighting on largescale strategic sites does not support small and medium sized house builders, and also could impact the ability for sites to come forward in a timely manner to enable a rolling five-year housing land supply.

Appendix D of the Local Plan states that upon adoption (2028), Greater Cambridge will be able to demonstrate a 5.47-year housing land supply. However, this based on the
Liverpool method to assessing housing land supply which is not the method preferred by Government. Paragraph 68-031 of the Planning Practice Guidance (PPG) states that “the level of deficit or shortfall will need to be calculated from the base date of the adopted plan
and should be added to the plan requirements for the next 5 year period (the Sedgefield approach), then the appropriate buffer should be applied”.

With the emerging Local Plan using the Liverpool method, the approach taken is not consistent with the PPG.
If the Local Plan were to use the Sedgefield approach, Greater Cambridge would only be able to demonstrate a 5.03 year supply, which does not provide a suitable buffer. The use of this Method therefore further highlights the issue of the development strategy by using larger strategic sites which would not be delivered until later in the Plan Period. With the approach not being sound or consistent with national policy, the Local Plan should use
the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.

Thakeham recommends allocating more smaller rural sites and using the Government-preferred Sedgefield method to
demonstrate a more robust five-year housing land supply.

As set out within draft Policy S/JH, the emerging Local Plan seeks to deliver at least 48,069 new homes within the Plan Period (2024-2045). In accordance with paragraph 62 of the National Planning Policy Framework (NPPF), this has been derived through the use of a standard method, which sets an annual requirement of 2,289 dwellings.

Whilst Policy S/JH seeks to meet its Local Housing Need (LHN), it is noted in paragraph 5, that the delivery is made up through the delivery of Neighbourhood Plans. Appendix C sets out that that the Local Plan is requiring 27 Neighbourhood areas to deliver 1,543 homes through Neighbourhood Plans.

Whilst Thakeham supports Neighbourhood Plans being used to deliver benefits to the local community, it does not support the Council’s intention for Neighbourhood Plans to
be relied upon to deliver rural growth. Instead, the Council must plan positively and ensure that the emerging Local Plan allocates sufficient sites to meet its housing need in full and ensure the vitality of rural settlements which the current emerging Local Plan does not seek to do.

The draft policy does not ensure the Local Plan is positively prepared as required under paragraph 36 of the 2024 NPPF, and also fails to recognise that some Neighbourhood Plans which have housing requirements within the draft Local Plan, have recently been ‘made’ and therefore are unlikely to be renewed in the short to medium term. An example of this would be the Fulbourn Neighbourhood Plan which was ‘made’ in March 2023.
Appendix C identifies that the Neighbourhood Plan should allocate a minimum of 101 dwellings; however, the ‘made’ Neighbourhood Plan does not allocate a single allocation,
therefore significantly short of the housing requirement set out within Appendix C. Despite the Neighbourhood Plan being three years old, Appendix C is suggesting that the Parish Council will need to go through the Neighbourhood Plan process again to allocate this requirement.

It should also be noted that following the Ministry for Housing, Communities and Local Government’s (MHCLG) announcement in June 2025, MHCLG has withdrawn
Neighbourhood Plan funding and planning support services from 2025 onwards. This announcement means that Neighbourhood Plans are now less likely to come forward, bringing doubt on the delivery of homes through Neighbourhood Plans. Furthermore, Neighbourhood Plans are slow to produce and will therefore not facilitate and enable the delivery of housing in the initial years of the plan. If the Council continues with its current approach, it is difficult to see how it will have five-year housing land supply at the point of adoption, leading to an immediate review and speculative planning applications, which
undermines the purpose of the plan-led system.

Considering the above, the current reliance on 1,543 being delivered through Neighbourhood Plans is an unsuitable method of ensuring housing delivery and results in the draft Local Plan not being prepared positively in accordance with paragraph 15 of the NPPF.

To ensure the prosperity of rural areas and ensure that key community facilities are delivered, the emerging Local Plan should seek to allocate additional sites within the rural area.

The proposed development strategy outlined within Policy S/DS seeks to rely on existing allocations and permissions to deliver 38,378 homes, with an additional 13,654 dwellings identified through brownfield redevelopment, new towns and large-scale strategic allocations. Whilst Thakeham acknowledges and supports that the Council has sought to meet its Local Housing Need (LHN) in full and provide an 8.2% buffer, the spatial strategy
is heavily reliant on the delivery of new settlements and large-scale development on the edge of Cambridge. As outlined in figure 9, previous growth has looked to be fairly evenly split across the different growth distributions. However, the proposed distribution in the emerging Local Plan seeks to deliver nearly half of its growth through ‘new settlements’ with only 15% delivered within the rural area. The underutilisation of the rural area leaves rural settlements vulnerable to seeing community facilities become unviable and therefore close down. By not supporting growth in rural areas, the Local Plan could see rural settlements become less sustainable and more reliant on travel to access key facilities.

As well as the underutilisation of rural growth, the emerging Local Plan seeks to deliver 81% of the homes on sites of 1,000 or more homes. The heavy weighting on largescale strategic sites does not support small and medium sized house builders, and also could impact the ability for sites to come forward in a timely manner to enable a rolling five-year housing land supply.

Appendix D of the Local Plan states that upon adoption (2028), Greater Cambridge will be able to demonstrate a 5.47-year housing land supply. However, this based on the
Liverpool method to assessing housing land supply which is not the method preferred by Government. Paragraph 68-031 of the Planning Practice Guidance (PPG) states that “the level of deficit or shortfall will need to be calculated from the base date of the adopted plan
and should be added to the plan requirements for the next 5 year period (the Sedgefield approach), then the appropriate buffer should be applied”.

With the emerging Local Plan using the Liverpool method, the approach taken is not consistent with the PPG.
If the Local Plan were to use the Sedgefield approach, Greater Cambridge would only be able to demonstrate a 5.03 year supply, which does not provide a suitable buffer. The use of this Method therefore further highlights the issue of the development strategy by using larger strategic sites which would not be delivered until later in the Plan Period. With the approach not being sound or consistent with national policy, the Local Plan should use
the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.

Allocation of site

As set out within draft Policy S/JH, the emerging Local Plan seeks to deliver at least 48,069 new homes within the Plan Period (2024-2045). In accordance with paragraph 62 of the National Planning Policy Framework (NPPF), this has been derived through the use of a standard method, which sets an annual requirement of 2,289 dwellings.
Whilst Policy S/JH seeks to meet its Local Housing Need (LHN), it is noted in paragraph 5, that the delivery is made up through the delivery of Neighbourhood Plans. Appendix C sets out that that the Local Plan is requiring 27 Neighbourhood areas to deliver 1,543 homes through Neighbourhood Plans.
Whilst Thakeham supports Neighbourhood Plans being used to deliver benefits to the local community, it does not support the Council’s intention for Neighbourhood Plans to be relied upon to deliver rural growth. Instead, the Council must plan positively and ensure that the emerging Local Plan allocates sufficient sites to meet its housing need in full and ensure the vitality of rural settlements which the current emerging Local Plan does not seek to do.
The draft policy does not ensure the Local Plan is positively prepared as required under paragraph 36 of the 2024 NPPF, and also fails to recognise that some Neighbourhood Plans which have housing requirements within the draft Local Plan, have recently been ‘made’ and therefore are unlikely to be renewed in the short to medium term. An example of this would be the Fulbourn Neighbourhood Plan which was ‘made’ in March 2023. Appendix C identifies that the Neighbourhood Plan should allocate a minimum of 101 dwellings; however, the ‘made’ Neighbourhood Plan does not allocate a single allocation, therefore significantly short of the housing requirement set out within Appendix C. Despite the Neighbourhood Plan being three years old, Appendix C is suggesting that the Parish Council will need to go through the Neighbourhood Plan process again to allocate this requirement.
It should also be noted that following the Ministry for Housing, Communities and Local Government’s (MHCLG) announcement in June 2025, MHCLG has withdrawn Neighbourhood Plan funding and planning support services from 2025 onwards. This announcement means that Neighbourhood Plans are now less likely to come forward, bringing doubt on the delivery of homes through Neighbourhood Plans. Furthermore, Neighbourhood Plans are slow to produce and will therefore not facilitate and enable the delivery of housing in the initial years of the plan. If the Council continues with its current approach, it is difficult to see how it will have five-year housing land supply at the point of adoption, leading to an immediate review and speculative planning applications, which undermines the purpose of the plan-led system.
Considering the above, the current reliance on 1,543 being delivered through Neighbourhood Plans is an unsuitable method of ensuring housing delivery and results in the draft Local Plan not being prepared positively in accordance with paragraph 15 of the NPPF.
To ensure the prosperity of rural areas and ensure that key community facilities are delivered, the emerging Local Plan should seek to allocate additional sites within the rural area.
The proposed development strategy outlined within Policy S/DS seeks to rely on existing allocations and permissions to deliver 38,378 homes, with an additional 13,654 dwellings identified through brownfield redevelopment, new towns and large-scale strategic allocations. Whilst Thakeham acknowledges and supports that the Council has sought to meet its Local Housing Need (LHN) in full and provide an 8.2% buffer, the spatial strategy is heavily reliant on the delivery of new settlements and large-scale development on the edge of Cambridge. As outlined in figure 9, previous growth has looked to be fairly evenly split across the different growth distributions. However, the proposed distribution in the emerging Local Plan seeks to deliver nearly half of its growth through ‘new settlements’ with only 15% delivered within the rural area. The underutilisation of the rural area leaves rural settlements vulnerable to seeing community facilities become unviable and therefore close down. By not supporting growth in rural areas, the Local Plan could see rural settlements become less sustainable and more reliant on travel to access key facilities.
As well as the underutilisation of rural growth, the emerging Local Plan seeks to deliver 81% of the homes on sites of 1,000 or more homes. The heavy weighting on largescale strategic sites does not support small and medium sized house builders, and also could impact the ability for sites to come forward in a timely manner to enable a rolling five-year housing land supply.
Appendix D of the Local Plan states that upon adoption (2028), Greater Cambridge will be able to demonstrate a 5.47-year housing land supply. However, this based on the Liverpool method to assessing housing land supply which is not the method preferred by Government. Paragraph 68-031 of the Planning Practice Guidance (PPG) states that “the level of deficit or shortfall will need to be calculated from the base date of the adopted plan and should be added to the plan requirements for the next 5 year period (the Sedgefield approach), then the appropriate buffer should be applied”.
With the emerging Local Plan using the Liverpool method, the approach taken is not consistent with the PPG.
If the Local Plan were to use the Sedgefield approach, Greater Cambridge would only be able to demonstrate a 5.03 year supply, which does not provide a suitable buffer. The use of this Method therefore further highlights the issue of the development strategy by using larger strategic sites which would not be delivered until later in the Plan Period. With the approach not being sound or consistent with national policy, the Local Plan should use the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.

Proposed modifications to soundness and legal compliance has been set out in the supporting representations. As outlined within the response to Section 3, Thakeham would advise that the spatial strategy needs to change, with the Local Plan allocating rural sites Local Plan not relying on Neighbourhood Plans to deliver rural growth, and instead the Local Plan should allocate sites in rural settlements to support their growth and maintain facilities.
Thakeham also raised that the approach to meeting its housing land supply is not consistent with national policy or sound. The Local Plan should use the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.
Full detail of Thakeham’s proposed modifications are set out within the submitted representations.

As set out within draft Policy S/JH, the emerging Local Plan seeks to deliver at least 48,069 new homes within the Plan Period (2024-2045). In accordance with paragraph 62 of the National Planning Policy Framework (NPPF), this has been derived through the use of a standard method, which sets an annual requirement of 2,289 dwellings.
Whilst Policy S/JH seeks to meet its Local Housing Need (LHN), it is noted in paragraph 5, that the delivery is made up through the delivery of Neighbourhood Plans. Appendix C sets out that that the Local Plan is requiring 27 Neighbourhood areas to deliver 1,543 homes through Neighbourhood Plans.
Whilst Thakeham supports Neighbourhood Plans being used to deliver benefits to the local community, it does not support the Council’s intention for Neighbourhood Plans to be relied upon to deliver rural growth. Instead, the Council must plan positively and ensure that the emerging Local Plan allocates sufficient sites to meet its housing need in full and ensure the vitality of rural settlements which the current emerging Local Plan does not seek to do.
The draft policy does not ensure the Local Plan is positively prepared as required under paragraph 36 of the 2024 NPPF, and also fails to recognise that some Neighbourhood Plans which have housing requirements within the draft Local Plan, have recently been ‘made’ and therefore are unlikely to be renewed in the short to medium term. An example of this would be the Fulbourn Neighbourhood Plan which was ‘made’ in March 2023. Appendix C identifies that the Neighbourhood Plan should allocate a minimum of 101 dwellings; however, the ‘made’ Neighbourhood Plan does not allocate a single allocation, therefore significantly short of the housing requirement set out within Appendix C. Despite the Neighbourhood Plan being three years old, Appendix C is suggesting that the Parish Council will need to go through the Neighbourhood Plan process again to allocate this requirement.
It should also be noted that following the Ministry for Housing, Communities and Local Government’s (MHCLG) announcement in June 2025, MHCLG has withdrawn Neighbourhood Plan funding and planning support services from 2025 onwards. This announcement means that Neighbourhood Plans are now less likely to come forward, bringing doubt on the delivery of homes through Neighbourhood Plans. Furthermore, Neighbourhood Plans are slow to produce and will therefore not facilitate and enable the delivery of housing in the initial years of the plan. If the Council continues with its current approach, it is difficult to see how it will have five-year housing land supply at the point of adoption, leading to an immediate review and speculative planning applications, which undermines the purpose of the plan-led system.
Considering the above, the current reliance on 1,543 being delivered through Neighbourhood Plans is an unsuitable method of ensuring housing delivery and results in the draft Local Plan not being prepared positively in accordance with paragraph 15 of the NPPF.
To ensure the prosperity of rural areas and ensure that key community facilities are delivered, the emerging Local Plan should seek to allocate additional sites within the rural area.
The proposed development strategy outlined within Policy S/DS seeks to rely on existing allocations and permissions to deliver 38,378 homes, with an additional 13,654 dwellings identified through brownfield redevelopment, new towns and large-scale strategic allocations. Whilst Thakeham acknowledges and supports that the Council has sought to meet its Local Housing Need (LHN) in full and provide an 8.2% buffer, the spatial strategy is heavily reliant on the delivery of new settlements and large-scale development on the edge of Cambridge. As outlined in figure 9, previous growth has looked to be fairly evenly split across the different growth distributions. However, the proposed distribution in the emerging Local Plan seeks to deliver nearly half of its growth through ‘new settlements’ with only 15% delivered within the rural area. The underutilisation of the rural area leaves rural settlements vulnerable to seeing community facilities become unviable and therefore close down. By not supporting growth in rural areas, the Local Plan could see rural settlements become less sustainable and more reliant on travel to access key facilities.
As well as the underutilisation of rural growth, the emerging Local Plan seeks to deliver 81% of the homes on sites of 1,000 or more homes. The heavy weighting on largescale strategic sites does not support small and medium sized house builders, and also could impact the ability for sites to come forward in a timely manner to enable a rolling five-year housing land supply.
Appendix D of the Local Plan states that upon adoption (2028), Greater Cambridge will be able to demonstrate a 5.47-year housing land supply. However, this based on the Liverpool method to assessing housing land supply which is not the method preferred by Government. Paragraph 68-031 of the Planning Practice Guidance (PPG) states that “the level of deficit or shortfall will need to be calculated from the base date of the adopted plan and should be added to the plan requirements for the next 5 year period (the Sedgefield approach), then the appropriate buffer should be applied”.
With the emerging Local Plan using the Liverpool method, the approach taken is not consistent with the PPG.
If the Local Plan were to use the Sedgefield approach, Greater Cambridge would only be able to demonstrate a 5.03 year supply, which does not provide a suitable buffer. The use of this Method therefore further highlights the issue of the development strategy by using larger strategic sites which would not be delivered until later in the Plan Period. With the approach not being sound or consistent with national policy, the Local Plan should use the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.

As set out within draft Policy S/JH, the emerging Local Plan seeks to deliver at least 48,069 new homes within the Plan Period (2024-2045). In accordance with paragraph 62 of the National Planning Policy Framework (NPPF), this has been derived through the use of a standard method, which sets an annual requirement of 2,289 dwellings.
Whilst Policy S/JH seeks to meet its Local Housing Need (LHN), it is noted in paragraph 5, that the delivery is made up through the delivery of Neighbourhood Plans. Appendix C sets out that that the Local Plan is requiring 27 Neighbourhood areas to deliver 1,543 homes through Neighbourhood Plans.
Whilst Thakeham supports Neighbourhood Plans being used to deliver benefits to the local community, it does not support the Council’s intention for Neighbourhood Plans to be relied upon to deliver rural growth. Instead, the Council must plan positively and ensure that the emerging Local Plan allocates sufficient sites to meet its housing need in full and ensure the vitality of rural settlements which the current emerging Local Plan does not seek to do.
The draft policy does not ensure the Local Plan is positively prepared as required under paragraph 36 of the 2024 NPPF, and also fails to recognise that some Neighbourhood Plans which have housing requirements within the draft Local Plan, have recently been ‘made’ and therefore are unlikely to be renewed in the short to medium term. An example of this would be the Fulbourn Neighbourhood Plan which was ‘made’ in March 2023. Appendix C identifies that the Neighbourhood Plan should allocate a minimum of 101 dwellings; however, the ‘made’ Neighbourhood Plan does not allocate a single allocation, therefore significantly short of the housing requirement set out within Appendix C. Despite the Neighbourhood Plan being three years old, Appendix C is suggesting that the Parish Council will need to go through the Neighbourhood Plan process again to allocate this requirement.
It should also be noted that following the Ministry for Housing, Communities and Local Government’s (MHCLG) announcement in June 2025, MHCLG has withdrawn Neighbourhood Plan funding and planning support services from 2025 onwards. This announcement means that Neighbourhood Plans are now less likely to come forward, bringing doubt on the delivery of homes through Neighbourhood Plans. Furthermore, Neighbourhood Plans are slow to produce and will therefore not facilitate and enable the delivery of housing in the initial years of the plan. If the Council continues with its current approach, it is difficult to see how it will have five-year housing land supply at the point of adoption, leading to an immediate review and speculative planning applications, which undermines the purpose of the plan-led system.
Considering the above, the current reliance on 1,543 being delivered through Neighbourhood Plans is an unsuitable method of ensuring housing delivery and results in the draft Local Plan not being prepared positively in accordance with paragraph 15 of the NPPF.
To ensure the prosperity of rural areas and ensure that key community facilities are delivered, the emerging Local Plan should seek to allocate additional sites within the rural area.
The proposed development strategy outlined within Policy S/DS seeks to rely on existing allocations and permissions to deliver 38,378 homes, with an additional 13,654 dwellings identified through brownfield redevelopment, new towns and large-scale strategic allocations. Whilst Thakeham acknowledges and supports that the Council has sought to meet its Local Housing Need (LHN) in full and provide an 8.2% buffer, the spatial strategy is heavily reliant on the delivery of new settlements and large-scale development on the edge of Cambridge. As outlined in figure 9, previous growth has looked to be fairly evenly split across the different growth distributions. However, the proposed distribution in the emerging Local Plan seeks to deliver nearly half of its growth through ‘new settlements’ with only 15% delivered within the rural area. The underutilisation of the rural area leaves rural settlements vulnerable to seeing community facilities become unviable and therefore close down. By not supporting growth in rural areas, the Local Plan could see rural settlements become less sustainable and more reliant on travel to access key facilities.
As well as the underutilisation of rural growth, the emerging Local Plan seeks to deliver 81% of the homes on sites of 1,000 or more homes. The heavy weighting on largescale strategic sites does not support small and medium sized house builders, and also could impact the ability for sites to come forward in a timely manner to enable a rolling five-year housing land supply.
Appendix D of the Local Plan states that upon adoption (2028), Greater Cambridge will be able to demonstrate a 5.47-year housing land supply. However, this based on the Liverpool method to assessing housing land supply which is not the method preferred by Government. Paragraph 68-031 of the Planning Practice Guidance (PPG) states that “the level of deficit or shortfall will need to be calculated from the base date of the adopted plan and should be added to the plan requirements for the next 5 year period (the Sedgefield approach), then the appropriate buffer should be applied”.
With the emerging Local Plan using the Liverpool method, the approach taken is not consistent with the PPG.
If the Local Plan were to use the Sedgefield approach, Greater Cambridge would only be able to demonstrate a 5.03 year supply, which does not provide a suitable buffer. The use of this Method therefore further highlights the issue of the development strategy by using larger strategic sites which would not be delivered until later in the Plan Period. With the approach not being sound or consistent with national policy, the Local Plan should use the Sedgefield method for assessing five-year housing land supply and allocate additional smaller sites to ensure a robust five-year housing land supply can be justified.